Open Spectrum

The Consumer Federation of America, Consumers Union, Free Press, Media Access Project, the New America Foundation, and Public Knowledge (together, the "Public Interest Commenters") respectfully submit this reply to initial comments filed in the above-captioned docket1 in response to the Commission's Notice of Inquiry (the "Notice"). The majority of those initial comments confirmed the Public Interest Commenters' conclusion that the mobile wireless ecosystem, including the commercial mobile services market itself and a range of upstream and

On behalf of the Public Interest Spectrum Coalition, we are pleased to submit these reply comments regarding the Commission's Notice of Inquiry on Fostering Innovation and Investment in the Wireless Communications Market.[1]   As the Commission noted, the market for wireless broadband services has been evolving at an extraordinarily rapid pace and is delivering new and empowering technologies to American

There is no doubt that consumer demand for mobile data applications is exploding worldwide. As Smartphones with PC capabilities and broadband aircards gain access to faster 4G networks beginning next year, total wireless data consumption will increase geometrically. Cisco’s annual projection of global Internet traffic predicts a 129% compound annual growth rate (CAGR) for mobile data over the next five years in North America (through 2013).

Meeting consumer demand for mobile data will require some combination of four strategies:

"The best available data suggests that the majority of federal spectrum capacity is left unused -- a situation that has gone largely unexamined," Sascha Meinrath, director of New America Foundation's open technology initiative, wrote in a June report.

As New America's Michael Calabrese puts it, "the vast majority of frequency bands are not being used in most locations and at most times."

As the FCC begins its year-long process to recommend a National Broadband Plan, one starting point is to unlock publicly-owned assets that can facilitate ubiquitous, affordable broadband access. Wireless spectrum remains the most cost-effective and rapid means to deliver broadband access to rural and unserved urban residents. But as mobile broadband use continues to increase exponentially, demand for spectrum will rapidly outpace availability under current spectrum management policies.

Wireless is the most cost-effective and rapid means to bring broadband access to under-served rural and urban residents. Even after high-capacity Internet access becomes universal, wireless remains as the complementary infrastructure needed to achieve the larger goal of pervasive connectivity. Within a few short years, most Americans are likely to spend more hours each week on mobile than on wired Internet connections. Demand for spectrum will outpace availability under current spectrum man-management policies. Meanwhile, in every… more

Dynamic Spectrum Access (DSA) Systems are one of the most promising technologies available to increase the range and efficiency of spectrum dependent services. DSA systems locate unused spectrum, and organize their users to operate within the spectrum they have identified. DSA systems ensure no interference to other users by scanning and sensing the environment, as the Defense Advanced Research Projects Agency (DARPA) NeXt Generation spectrum sharing field tests have established, or through pre-existing knowledge, such as the geolocation database… more

As the U.S. economy and society becomes more and more information-centric and mobile, wireless systems are becoming a major factor in the efficient functioning of our society. Radio spectrum is a key economic input into wireless systems that power our information society and economy and enhance public safety and national security. Since the earliest days of radio regulation in the United States; federal government use of spectrum has been handled independently of other users’ access to spectrum. … more

The time has arrived for the unmet potentials of federal white spaces to receive some well-deserved attention. While many policy analysts have focused on the fate of the 700 MHz auctions, the digital TV transition, and the promise of television white space devices, the best available data suggests that the majority of federal spectrum capacity is left unused (McHenry, 2003; McHenry, 2004) – a situation that has gone largely unexamined. Strategic reuse of this spectrum could help obviate the need… more